Lack of Oversight for Management of Exempt Sources Jim Grice, Radioactive Materials Unit Leader Colorado Department of Public Health and Environment

Exemptions for source and byproduct materials 10 CFR 32.11 through 32.40 Gas and Aerosol Detectors - 10 CFR 32.26 and 32.27 Detectors with Less than 1µCi Am-241 - 10 CFR 30.15

NRC Assessments CR-1156 – published in 1979 Primary assessment for exemption of household detectors (Am-241~3 µCi at that time) Life Cycle: Manufacture – distribution – sale – installation – use - landfill disposal Potential exposures: fire fighting and cleanup after fires Worst Case – ingestion during manufacture of household unit– 3 mrem

NRC Assessments NUREG-1717 – 2001 Gas and aerosol detectors one of many items assessed Cites info from the 1979 report and reconfirms safety Potential exposure cases – teacher removing household detector source (~1 µCi as is current today) and using for 10 hours a year – 0.001mrem dose Worst Case – ingestion during manufacture of household unit– 600 mrem Same Life Cycle: Manufacture – distribution – sale – installation – use - landfill disposal

NRC Public Communications/Positions Many NRC blogs, posts, and official communications:

NRC Public Communications/Positions Many NRC blogs, posts, and official communications: Smoked Detectors are to be used and disposed of at end of 10 year life cycle “The radioactive sources are in a form that does not break down or corrode over time. The source is sandwiched between two layers of metal and rolled thin. This “foil” is sealed inside the ionization chamber. The seal can only be broken by the deliberate use of force, such as taking a hammer to the smoke detector. The NRC discourages this kind of intentional destruction.” “To the extent that you possess domestic smoke detectors distributed to you as exempt units, you are exempt from any regulatory requirements. Therefore you may dispose of these units as ordinary trash”

NRC Public Communications/Positions SAFE!!

Reduce - Reuse - Recycle Current Culture: Reduce - Reuse - Recycle The Federal government promotes this idea: EPA USA.Gov President Obama Our culture tells us that to dispose of is bad.

Reduce - Reuse - Recycle Current Culture: Reduce - Reuse - Recycle The Federal government promotes this idea: EPA USA.Gov President Obama Our culture tells us that to dispose of is bad.

So what’s the problem? Some of these detectors had up to 80 µCi Am-241 Specifically: Pyrotronics Pyr-a-larm Models F5 and F3/5A

So what’s the problem? They are very old…some greater than 40 years old

So what’s the problem? Were used in many industries (Nuclear Reactors) Systems depend on them Not made any more Require Maintenance

So what’s the problem? Were used in many industries (Nuclear Reactors) Systems depend on them Not made any more Require Maintenance

So what’s the problem? Old buildings being torn down Readily available on EBay and from private owners

So what’s the problem? Difficult to find good information on these

So what’s the problem? Difficult to find good information on these

So what’s the problem? Difficult to find good information on these

So what’s the problem? Difficult to find good information on these

So what’s the problem? Time to Reduce Reuse and Recycle!!!

So what’s the problem? No good deed goes unpunished…

Case Study The source is one or more smoke detectors August 2015, Colorado Dept of Public Health receives communication from NRC regarding contamination at one of their licensed reactor facilities The source is one or more smoke detectors Detectors were serviced by a small company in Colorado

Case Study CDPHE visits residence and conducts a survey CDPHE contacts facility and learns that business operates from a private residence in a suburban neighborhood CDPHE visits residence and conducts a survey Small business has been operating for over 20 years – possessed hundreds of detectors - both 80 µCi and smaller 10-15 µCi units Servicing detectors and collecting them from old building removals for service and sale

Case Study Contamination is found in multiple work areas within the facility Work was confined to a basement shop room and the garage Removable contamination found as high as 19 nanoCuries per 100 cm2 Fixed contamination found as high as 22 nanoCuries per 100 cm2 Volumetric Contamination: ~50 pCi/g

Case Study While the maintenance did at times involve the disassembly of the detector heads some were cleaned only with steam or a sonic water/radiac wash bath This seems to indicate that the foils are failing over time Surprisingly easy to access the sources – ¼ turn on covers to reveal post mounted source and one small nut to reveal the cap sources

Case Study The business had over the years followed the servicing instructions per the original detector manufacturer service manuals – including the use of PPE Believed that he was doing the right thing by keeping his customers fire and particulate safety systems up and running and preventing these from going into landfills over the years Believed that exempt items were safe and sound since they did not require a license and were exempt from regulation

Case Study CDPHE orders business to cease and desist from performing any maintenance or distribution of smoke detectors and to hire a licensed contractor to fully characterize and decontaminate the facility and dispose of the wastes Results in thousands of dollars spent to mitigate the situation As of today the characterization and decommissioning activities are complete and CDPHE is reviewing their final status survey The residents of the home worked with the physicians at Oakridge and it was determined that they currently have no “intake of Am‐241 which would be of medical significance”

What’s the Point?? These devices should be removed from use…the 10 year mark has passed…the sources are no longer well contained These devices should be disposed of This should be clearly communicated to members of the public as well as industries who use these materials Make sure that any recyclers are aware of potential hazards and are required to have a RAM license if they want to accept and potentially manipulate smoke detectors We need a unified clear and concise message regarding the life cycle of these items and proper disposal As we navigate the culture of the 3 R’s we need to ensure that safety is priority number one

What’s the Point?? Reuse is good, but not when materials have exceeded their designed life cycle Recycling is good, but not in every case Landfill disposal of these items has been determined to be safe and protective When In Doubt…Throw It Out!!!

Thank You! Questions? Jim Grice, Radioactive Materials Unit Leader Colorado Department of Public Health and Environment james.grice@state.co.us – 303-692-3371